BIG WOLF CORP. v. COMMISSIONER OF INTERNAL REVENUE, 2 T.C. 751 (1943) BIG WOLF CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT. Docket No. 111852.United States Tax Court. Promulgated September 27, 1943. Petitioner’s transferor in 1916, pursuant to a recapitalization, exchanged 2,595 shares of X corporation’s stock for 2,076 new shares and a cash distribution. From […]
Category: United States Tax Court Opinions
GARTLAND v. COMMISSIONER OF INTERNAL REVENUE, 34 T.C. 867 (1960)
GARTLAND v. COMMISSIONER OF INTERNAL REVENUE, 34 T.C. 867 (1960) ESTATE OF LEO M. GARTLAND, DECEASED, MATTHEW GARTLAND, ADMINISTRATOR,PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Docket No. 81540.United States Tax Court. Filed August 18, 1960. Decedent’s father in 1929 created a trust providing for payment of income for life to decedent in discretion of trustee, […]
ESTATE OF HAMELSKY v. COMMISSIONER OF INTERNAL REVENUE, 58 T.C. 741 (1972)
ESTATE OF HAMELSKY v. COMMISSIONER OF INTERNAL REVENUE, 58 T.C. 741 (1972) ESTATE OF ABRAHAM HAMELSKY, DECEASED, SAMUEL HAMELSKY, EXECUTOR,PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 7511-70.United States Tax Court. Filed August 7, 1972. Decedent’s will provided that his executor could distribute assets in kind at their values as finally determined for Federal […]
O’BOYLE v. COMMISSIONER, 2010-149 (T.C.M. 7-13-2010)
O’BOYLE v. COMMISSIONER, 2010-149 (T.C.M. 7-13-2010) HAROLD X. O’BOYLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,Respondent SALLY R. O’BOYLE, Petitioner v. COMMISSIONER OF INTERNALREVENUE, Respondent Nos. 30214-07, 30215-07.[fn1]United States Tax Court. Filed July 13, 2010. [fn1] These cases were consolidated by order of this Court and are hereinafter referred to collectively as the instant case. MEMORANDUM […]
JOHNSON INVESTMENT RENTAL COMPANY v. COMMISSIONER, 70 T.C. 895 (1978)
JOHNSON INVESTMENT RENTAL COMPANY v. COMMISSIONER, 70 T.C. 895 (1978) JOHNSON INVESTMENT RENTAL COMPANY, PETITIONER v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 834-76.United States Tax Court. Filed September 11, 1978. P “leased” certain property to X, which operated a quarry thereon and paid P 5 cents for each ton of rock sold by it from […]
HAVENS STRUCTURAL STEEL CO. v. COMMISSIONER, 30 T.C. 1121 (1958)
HAVENS STRUCTURAL STEEL CO. v. COMMISSIONER, 30 T.C. 1121 (1958) HAVENS STRUCTURAL STEEL CO., PETITIONER, v. COMMISSIONER OF INTERNALREVENUE, RESPONDENT. Docket No. 28634.United States Tax Court. Filed August 21, 1958. Held, that assuming (but not deciding) that petitioner has established a qualifying factor under section 722 (b) (1) or 722 (b) (2) of the Code […]
KENTUCKY BAR FOUNDATION v. COMMR. OF INTERNAL REVENUE, 78 T.C. 921 (1982)
KENTUCKY BAR FOUNDATION v. COMMR. OF INTERNAL REVENUE, 78 T.C. 921 (1982) KENTUCKY BAR FOUNDATION, INC., A NON-STOCK, NON-PROFIT CORPORATION,PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. No. 14892-80X.United States Tax Court. Filed June 9, 1982. Petitioner, a nonprofit organization, was operated to accumulate funds for the purpose of acquiring land for and contributing to the […]
ESTATE OF HONICKMAN v. COMMR. OF INTERNAL REVENUE, 58 T.C. 132 (1972)
ESTATE OF HONICKMAN v. COMMR. OF INTERNAL REVENUE, 58 T.C. 132 (1972) ESTATE OF MAURICE H. HONICKMAN, DECEASED, KATE HONICKMAN, HAROLD A.HONICKMAN AND GIRARD TRUST BANK, COEXECUTORS, PETITIONERS v. COMMISSIONEROF INTERNAL REVENUE, RESPONDENT Docket No. 3660-69.United States Tax Court. Filed April 26, 1972. Decedent made transfers of certain property within 3 years preceding his death. […]
KRIEGER v. COMMISSIONER OF INTERNAL REVENUE, 64 T.C. 214 (1975)
KRIEGER v. COMMISSIONER OF INTERNAL REVENUE, 64 T.C. 214 (1975) GORDON L. KRIEGER AND MARY E. KRIEGER, PETITIONERS v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 3489-74.United States Tax Court. Filed May 8, 1975. Where an erroneous refund has been made to a taxpayer in respect of an excessive carryback of a net operating loss, the […]
HARTMAN v. COMMISSIONER OF INTERNAL REVENUE, 43 T.C. 105 (1964)
HARTMAN v. COMMISSIONER OF INTERNAL REVENUE, 43 T.C. 105 (1964) SANFORD H. HARTMAN AND HENRIETTA HARTMAN, PETITIONERS, v. COMMISSIONER OFINTERNAL REVENUE, RESPONDENTU.S. ASIATIC CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE,RESPONDENT Docket Nos. 1873-62, 1874-62, 1249-63, 2470-63.United States Tax Court. Filed October 26, 1964. 1. Held, that Shafford Co., which merchandised, distributed, and sold throughout […]